Object

Draft Black Country Plan

Representation ID: 20048

Received: 11/10/2021

Respondent: Rt Hon Valerie Vaz

Representation Summary:

The need in Walsall South is for family homes which are affordable and for social housing.
Currently there is provision for single household dwellings at Tameway Tower a large development in the Town Centre. However, there is no mention of social housing or working with Housing Associations.

The Draft Plan mentions that of the 13,344 new homes required 5,418 will be on land that is currently Green Belt. This means that 40% of the additional homes for Walsall will be built on the Green Belt in Walsall.

This is a huge incursion into the Walsall Green Belt and contravenes current planning law and guidelines.
The plan encourages the unrestricted sprawl of built-up areas, encroachment of countryside abutting the main urban district of Walsall town centre – countryside
which has the biggest social and health benefit and is within walking and cycling distance, proposes inappropriate merging of Pheasey and Streetly, undermines the special setting and characteristics of Walsall Arboretum, and discourages recycling of derelict and other urban land in Walsall and the wider Black Country.

The proposals amount to a continuous erosion of the Green Belt if they become the adopted Policy. There would be no requirement by a developer to provide
evidence that there were very special circumstances for building on the Green Belt.


What the consultation document does not do is shed any light on the ownership of land that is being designated for housing allocation. Much of this is Green Belt land and currently designated agricultural. Designation of this land for housing development massively increases the value of this land at a stroke. The public and other stakeholders should be notified as part of this consultation process about who owns the land subject to such change of use and therefore land value, what connections the landowners may have with councillors, officers, and political parties (such as through donations or membership) in order that the public can draw their own conclusions about such connections if in existence.

It is well known for example that developers land bank Green Belt and agricultural land on the edge of existing built environments in the hope that and even expectation that local planning policy will be changed and their speculative land banking of Green Belt will reap huge dividends for them.

4 Policy

Unlike the other Boroughs’ table of sites which indicate which site is on Green Belt or brownfield, Walsall’s Table 31 Page 506 fails to identify which parcel of land is on Green Belt. This is misleading the public.

The current policy on the Green Belt from the National Planning Policy Framework (NPPF) states:
137 The government attaches great importance to Green Belts. The fundamental aim of Green Belt policy is to prevent urban sprawl by keeping land permanently open; the essential characteristics of Green Belts are their openness and their permanence.

138. Green Belt serves 5 purposes:
(a) to check the unrestricted sprawl of large built-up areas;
(b) to prevent neighbouring towns merging into one another;
(c) to assist in safeguarding the countryside from encroachment;
(d) to preserve the setting and special character of historic towns; and
(e) to assist in urban regeneration, by encouraging the recycling of derelict and other urban land.

To include and redraw the Green Belt in the current draft plan contravenes the NPPF.

The narrative for Walsall does not set out why those tests should be overridden and once they are in the plan, there would therefore be no need to be any justification at the planning permission stage that there are very special circumstances to justify building on the Green Belt.

Moreover the sites that are suggested are either on or near Sites of Local Importance for Nature Conservation SLINC and/or agricultural land. The policy document is silent on more efficient use of this land for local agricultural and community purposes.

Conclusion

For all those reasons, and the fact that many constituents have contacted me with serious concerns and objections, I would submit that the land identified as follows should be removed from the draft plan:

• WAH242 Calderfields West (breaching s138 (a) (c) (d) as it adjoins Walsall Arboretum, and (e)